In this NERA seminar, held in Paris on 12 December 2013, Senior Vice Presidents Dr. Emmanuel Llinares and Dr. Alan Cox and Vice President Sébastien Gonnet discussed how to identify and map intangibles within multinational enterprises (MNEs), and presented the economic framework for intangibles valuation. The identification of intangibles, the determination of intangibles-related returns, and their allocation among the various tax jurisdictions of the MNE are at the center of a number of international discussions being led by the OECD, which include the revision of the OECD Guidelines Chapter 6 covering intangibles and the Base Erosion Profit Shifting project initiated by the G20. NERA's experts also presented several case studies during the seminar. Dr. Cox presented economic techniques used in the context of intellectual property litigation in the US, and commented that such techniques could have relevance in the transfer pricing context as well.

NERA's presentation can be downloaded here.